interpretation clause (New York) · Go Syfert
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interpretation clause in New York

48 New York opinions name it 7 courts 1896–2022 1 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Town of Harrison v. County of Westchestergreen
ny · 1963 · cited in 2 New York opinions naming this issue, 1975–1979
2 sentences

1979The argument that they are one and the same was rejected in Town of Harrison v County of Westchester ( 13 NY2d 258, 265 ), where the court said: "The argument is, in effect, that, since the Legislature has there been held empowered to authorize the condemnation of property for a 'public use’ even though some of the property is to be leased to private parties, the same interpretation of the standard of 'public use’ must necessarily be applied in determining the tax status of such property.

1975The Court of Appeals rejected that contention in these words ( 13 NY2d 258, 265, 266 , supra): "While the argument may have superficial appeal, it cannot withstand analysis since the two situations are completely disparate as respects both the policy considerations and the issues involved.

12
Schumacher v. Secretary Of Health And Human Servicesgreen
cafc · 1993 · cited in 1 New York opinions naming this issue, 2022–2022
1 sentence

2022The legislative history supports that interpretation ( see Schumacher v Secretary of Dept. of Health and Human Servs. , 2 F3d 1128, 1132-1134 [Fed Cir 1993] [concluding that the legislative history supports a narrow interpretation of the bar on civil actions]; Amendola v Secretary, Dept. of Health and Human Servs. , 989 F2d 1180, 1185-1186 [Fed Cir 1993] ["Congress clearly intended by the amendment to apply the [VICP] to pediatricians who administered a vaccine as well as to the manufacturer who made it"]).

11
Melendez-Diaz v. Massachusettsgreen
scotus · 2009 · cited in 1 New York opinions naming this issue, 2014–2014
1 sentence

2014In general, forensic laboratory procedures, which may involve the application of expertise involving the handling of the evidence to be tested, preparing an instrument to perform an analysis, the procedures followed to conduct the analysis, and the interpretation of test results, represent a significant amount of information “meet for cross-examination” (Bullcoming, 564 US at —, 131 S Ct at 2714; see also Melendez-Diaz v Massachusetts, 557 US 305 , 311 n 1 [2009] [“chain of custody, authenticity of the sample, (and the) accuracy of the testing device” are salient matters for authenticating tes

11
Rentways, Inc. v. O'Neill Milk & Cream Co.green
ny · 1955 · cited in 1 New York opinions naming this issue, 2012–2012
1 sentence

2012This interpretation of the clause best accords with the remainder of the lease (see Rentways, Inc. v O’Neill Milk & Cream Co., 308 NY 342, 347 [1955]).

11
Kramarik v. Travelersgreen
nyappdiv · 2006 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Such a result would have obviously been at odds with Bennett’s “reasonable expectations as a businessperson seeking insurance coverage for injuries resulting from the operation of his [painting] business” (Kramarik v Travelers, 25 AD3d 960, 962 [2006]).

11
People v. Ohrensteingreen
ny · 1990 · cited in 1 New York opinions naming this issue, 2004–2004
2 sentences

2004Thus, the Court of Appeals has said that the clause applies to committee meetings and hearings that do not occur on the floor of the House (People v Ohrenstein, 77 NY2d at 54; see also Matter of Straniere v Silver, 218 AD2d 80, 83 [3d Dept 1996]), but “does not extend to acts which a legislator performs to secure support in the community or to insure reelection, such as giving speeches in the community, issuing newsletters and press releases, or arranging for the publication of books.” (People v Ohrenstein, 77 NY2d at 54, citing Hutchinson v Proxmire, 443 US 111 [1979].) In order to be protect

2004Thus, the Court of Appeals has said that the clause applies to committee meetings and hearings that do not occur on the floor of the House (People v Ohrenstein, 77 NY2d at 54; see also Matter of Straniere v Silver, 218 AD2d 80, 83 [3d Dept 1996]), but “does not extend to acts which a legislator performs to secure support in the community or to insure reelection, such as giving speeches in the community, issuing newsletters and press releases, or arranging for the publication of books.” (People v Ohrenstein, 77 NY2d at 54, citing Hutchinson v Proxmire, 443 US 111 [1979].) In order to be protect

11
United States v. Brewstergreen
scotus · 1972 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004(Oates v Marino, 106 AD2d 289 [1st Dept 1984] [Senator’s allegedly defamatory remarks made during public hearing were protected under clause]; see also United States v Brewster, 408 US 501, 507 [1972] [“(t)he immunities of the Speech or Debate Clause . . . (exist) to protect the integrity of the legislative process by insuring the independence of individual legislators”].) While the interpretation of the clause has been expanded to incorporate some legislative activity beyond floor speeches and House debate, the act in question must still be legislative in nature.

11
Straniere v. Silvergreen
nyappdiv · 1996 · cited in 1 New York opinions naming this issue, 2004–2004
2 sentences

2004Thus, the Court of Appeals has said that the clause applies to committee meetings and hearings that do not occur on the floor of the House (People v Ohrenstein, 77 NY2d at 54; see also Matter of Straniere v Silver, 218 AD2d 80, 83 [3d Dept 1996]), but “does not extend to acts which a legislator performs to secure support in the community or to insure reelection, such as giving speeches in the community, issuing newsletters and press releases, or arranging for the publication of books.” (People v Ohrenstein, 77 NY2d at 54, citing Hutchinson v Proxmire, 443 US 111 [1979].) In order to be protect

2004Thus, the Court of Appeals has said that the clause applies to committee meetings and hearings that do not occur on the floor of the House (People v Ohrenstein, 77 NY2d at 54; see also Matter of Straniere v Silver, 218 AD2d 80, 83 [3d Dept 1996]), but “does not extend to acts which a legislator performs to secure support in the community or to insure reelection, such as giving speeches in the community, issuing newsletters and press releases, or arranging for the publication of books.” (People v Ohrenstein, 77 NY2d at 54, citing Hutchinson v Proxmire, 443 US 111 [1979].) In order to be protect

11
Gravel v. United Statesgreen
scotus · 1972 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Thus, the Court of Appeals has said that the clause applies to committee meetings and hearings that do not occur on the floor of the House (People v Ohrenstein, 77 NY2d at 54; see also Matter of Straniere v Silver, 218 AD2d 80, 83 [3d Dept 1996]), but “does not extend to acts which a legislator performs to secure support in the community or to insure reelection, such as giving speeches in the community, issuing newsletters and press releases, or arranging for the publication of books.” (People v Ohrenstein, 77 NY2d at 54, citing Hutchinson v Proxmire, 443 US 111 [1979].) In order to be protect

11
Hutchinson v. Proxmiregreen
scotus · 1979 · cited in 1 New York opinions naming this issue, 2004–2004
1 sentence

2004Thus, the Court of Appeals has said that the clause applies to committee meetings and hearings that do not occur on the floor of the House (People v Ohrenstein, 77 NY2d at 54; see also Matter of Straniere v Silver, 218 AD2d 80, 83 [3d Dept 1996]), but “does not extend to acts which a legislator performs to secure support in the community or to insure reelection, such as giving speeches in the community, issuing newsletters and press releases, or arranging for the publication of books.” (People v Ohrenstein, 77 NY2d at 54, citing Hutchinson v Proxmire, 443 US 111 [1979].) In order to be protect

11
Garcia v. Brattongreen
nyappdiv · 1996 · cited in 1 New York opinions naming this issue, 1997–1997
1 sentence

1997As a matter of public policy, the Police Department’s interpretation of rule 5.2.8 (b) is eminently sensible” (Matter of Garcia v Bratton, 225 AD2d 123, 127).

11
Auerbach v. Bennettgreen
nyappdiv · 1978 · cited in 1 New York opinions naming this issue, 1979–1979
11
Whiteside v. Insurance Co. of Pennsylvaniagreen
nyappdiv · 1948 · cited in 1 New York opinions naming this issue, 1968–1968
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (63)

CaseCitedYears
Howard v. Wyman green
ny · 1971
2 sentences

1996This interpretation of the rule is not irrational, and should therefore be upheld (see, e.g., Matter of Howard v Wyman, 28 NY2d 434 ; McGowan v Burstein, 71 NY2d 729 ; Matter of Henry v Coughlin, 214 AD2d 673 ).

1979It has been held "that the construction given statutes and regulations by the agency responsible for their administration, if not irrational or unreasonable, should be upheld” (Matter of Howard v Wyman, 28 NY2d 434, 438 ).

21979–1996
Crucen v. Leary green
nyappdiv · 2008
1 sentence

2022Our prior decision in Crucen v Leary ( 55 AD3d 510 [2008]) is not to the contrary.

12022–2022
Nestorowich v. Ricotta green
ny · 2002
1 sentence

2020An interpretation of the rule so as to categorize cessation or continuance of the same treatment as a choice "between or among medically acceptable alternatives" contemplated under Nestorowich would expand the application of the charge and "would transform it from a protection against second-guessing of genuine exercises of professional judgment in treatment or diagnosis into a cloak for professional misfeasance" ( Nestorowich v Ricotta , 97 NY2d at 399 ).

12020–2020
Coeur Alaska, Inc. v. Southeast Alaska Conservation Council green
scotus · 2009
1 sentence

2012Consequently, the Justice Court should have proceeded to examine the PHMSA’s interpretation of the rule (see Coeur Alaska, Inc., 557 US at 278 ).

12012–2012
Paragas v. Comsewogue Union Free School District green
nyappdiv · 2009
1 sentence

2009Accordingly, the proximate cause of the plaintiffs injuries was not the defendants’ alleged failure to issue a proper instruction regarding the act of “highsticking” (see generally Paragas v Comsewogue Union Free School Dist., 65 AD3d 1111 [2009]; cf. Mei Kay Chan v City of Yonkers, 34 AD3d 540 [2006]).

12009–2009
Mei Kay Chan v. City of Yonkers green
nyappdiv · 2006
1 sentence

2009Accordingly, the proximate cause of the plaintiffs injuries was not the defendants’ alleged failure to issue a proper instruction regarding the act of “highsticking” (see generally Paragas v Comsewogue Union Free School Dist., 65 AD3d 1111 [2009]; cf. Mei Kay Chan v City of Yonkers, 34 AD3d 540 [2006]).

12009–2009
Oates v. Marino green
nyappdiv · 1984
1 sentence

2004(Oates v Marino, 106 AD2d 289 [1st Dept 1984] [Senator’s allegedly defamatory remarks made during public hearing were protected under clause]; see also United States v Brewster, 408 US 501, 507 [1972] [“(t)he immunities of the Speech or Debate Clause . . . (exist) to protect the integrity of the legislative process by insuring the independence of individual legislators”].) While the interpretation of the clause has been expanded to incorporate some legislative activity beyond floor speeches and House debate, the act in question must still be legislative in nature.

12004–2004
Seidlitz v. . Auerbach green
ny · 1920
1 sentence

2002In Seidlitz v Auerbach (supra), the liquidated damages provision was invalidated where the lease term at issue provided that the tenant would forfeit its entire security deposit, representing more than one year’s rent, for any contractual default, ranging from the failure to pay rent to the failure to pay a $17 insurance premium.

12002–2002
Bourgeois v. North Shore University Hospital at Forest Hills green
nyappdiv · 2002
1 sentence

2002Hosp. at Forest Hills, 290 AD 2d 525 ; Fhima v Maimonides Med.

12002–2002
New York City Friends of Ferrets v. City of New York green
nysd · 1995
1 sentence

1999The determination whether ferrets are in fact “a species which is wild, ferocious, fierce, dangerous or naturally inclined to do harm” (24 RCNY 161.01 [a]) also was left open in New York City Friends of Ferrets v City of New York (876 F Supp 529, supra).

11999–1999
Consolidated Edison Co. of New York, Inc. v. Hartford Insurance green
nyappdiv · 1994
1 sentence

1997Co. ( 203 AD2d 83 ) that the additional insured clause does not focus on the cause of the accident but upon the "general nature of the operation in the course of which the injury was sustained” (supra, at 83), reads out of the endorsement the key words limiting coverage for the additional insured, insofar as relevant to the issue at hand, to "its liability * * * for 'your work’ for or on behalf of the Additional Insured.” * The majority interprets the endorsement to provide additional insured coverage as long as the party making a claim against the additional insured sustained injuries in the

11997–1997
Tomlinson v. Ward green
nyappdiv · 1985
1 sentence

1996(Tomlinson v Ward, 110 AD2d 537, 538 , affd 66 NY2d 771 .) While petitioner was on modified duty with the Motor Transport Division she was not performing the duties of a police officer since her weapon and shield had been removed and her merit and fitness as a police officer could not be evaluated.

11996–1996
Wegman v. Wegman green
nyappdiv · 1986
1 sentence

1996The court had concluded that while the cases had established commencement date rule for "active” assets and a trial date rule for "passive” assets, the cases did not support a strict interpretation of the rule and that the trial court has the obligation to review each case on its own facts (see, Wegman v Wegman, 123 AD2d 220 ).

11996–1996
MATTER OF TOMLINSON v. Ward green
ny · 1985
1 sentence

1996(Tomlinson v Ward, 110 AD2d 537, 538 , affd 66 NY2d 771 .) While petitioner was on modified duty with the Motor Transport Division she was not performing the duties of a police officer since her weapon and shield had been removed and her merit and fitness as a police officer could not be evaluated.

11996–1996
Henry v. Coughlin neutral
nyappdiv · 1995
1 sentence

1996This interpretation of the rule is not irrational, and should therefore be upheld (see, e.g., Matter of Howard v Wyman, 28 NY2d 434 ; McGowan v Burstein, 71 NY2d 729 ; Matter of Henry v Coughlin, 214 AD2d 673 ).

11996–1996
McSparron v. McSparron green
ny · 1995
1 sentence

1996That analysis was reaffirmed by the McSparron decision (supra) In McSparron the Court of Appeals held that the active/passive formulation "may prove too rigid to be useful” and the distinctions "should be regarded only as helpful guideposts and not as immutable rules of law” (McSparron v McSparron, supra, 87 NY2d, at 288 ).

11996–1996
McGowan v. Burstein green
ny · 1988
1 sentence

1996This interpretation of the rule is not irrational, and should therefore be upheld (see, e.g., Matter of Howard v Wyman, 28 NY2d 434 ; McGowan v Burstein, 71 NY2d 729 ; Matter of Henry v Coughlin, 214 AD2d 673 ).

11996–1996
Alexander v. Alexander green
ohprobctfrankli · 1988
11993–1993
Batcheldor v. Boyd green
ncctapp · 1992
1 sentence

1993(Cf., Alexander v Alexander, 42 Ohio Misc 2d 30, 537 NE2d 1310 , appeal dismissed 54 Ohio App 3d 77, 560 NE2d 1337 ; Estate of Greenwood, 402 Pa Super 536, 587 A2d 749 ; Batcheldor v Boyd, 108 NC App 275, 423 SE2d 810 .) Although nothing in clause (C) prohibits postdeath blood testing, public policy considerations may warrant such a limitation (see, Lalli v Lalli, 439 US 259 ).

11993–1993
Lalli v. Lalli green
scotus · 1978
11993–1993
In Re Estate of Greenwood green
pasuperct · 1991
11993–1993
Alexander v. Alexander green
ohioctapp · 1989
1 sentence

1993(Cf., Alexander v Alexander, 42 Ohio Misc 2d 30, 537 NE2d 1310 , appeal dismissed 54 Ohio App 3d 77, 560 NE2d 1337 ; Estate of Greenwood, 402 Pa Super 536, 587 A2d 749 ; Batcheldor v Boyd, 108 NC App 275, 423 SE2d 810 .) Although nothing in clause (C) prohibits postdeath blood testing, public policy considerations may warrant such a limitation (see, Lalli v Lalli, 439 US 259 ).

11993–1993
Weiss v. Fote green
ny · 1960
11989–1989
In re the Estate of Bellinger green
nyappdiv · 1977
11985–1985
In re the Estate of Smith green
nysurct · 1938
11985–1985
Hennig v. Goldberg neutral
nynyccityct · 1947
11984–1984
In Re the Arbitration Between National Cash Register Co. & Wilson green
ny · 1960
11984–1984
Greene v. Donnelly neutral
nyappdiv · 1923
11984–1984
In re the Arbitration between Local Division 1179, Amalgamated Transit Union & Green Bus Lines, Inc. green
ny · 1980
11984–1984
Norris v. Cooper green
ny · 1984
11984–1984
Rosemary W. v. Bruce A. neutral
nycfamct · 1982
11982–1982
Lomonaco v. James McKinney & Son, Inc. neutral
nyappdiv · 1976
11980–1980
Foley v. D'Agostino green
nyappdiv · 1964
11979–1979
Traendly v. State neutral
ny · 1977
11978–1978
Terranova v. Emil green
ny · 1967
11978–1978
Bank of New York v. Hirschfeld green
ny · 1975
11978–1978
Cohen v. Levine neutral
nysupct · 1969
11970–1970
Chavers v. St. Paul Fire and Marine Insurance Company neutral
ohnd · 1960
11970–1970
Nick Chavers v. St. Paul Fire & Marine Insurance Company neutral
ca6 · 1961
11970–1970
In re the Probate of the Will of Dombek neutral
nyappdiv · 1952
11967–1967

Where else courts name it

TX 117 (1913–2025) IL 109 (1877–2026) CA 93 (1912–2026) UT 83 (1988–2026) FL 81 (1959–2025) MI 68 (1949–2025) OR 67 (1893–2026) PA 65 (1897–2025) NY 48 (1896–2022) CO 45 (1952–2026) OH 45 (1926–2025) IA 37 (1941–2024) MN 37 (1967–2026) WI 35 (1923–2024) AR 35 (1929–2025) WA 34 (1918–2019) MD 34 (1943–2023) MO 32 (1899–2020) AZ 31 (1946–2024) CT 29 (1955–2023) NJ 28 (1869–2020) HI 28 (1978–2022) MA 28 (1863–2026) IN 26 (1941–2023) WV 25 (1913–2024) MS 22 (1895–2023) LA 21 (1937–2019) NC 20 (1912–2020) AL 19 (1885–2008) NM 18 (1939–2019) GA 16 (1909–2024) MT 16 (1890–2023) TN 15 (1942–2022) ND 15 (1974–2023) DC 14 (1975–2024) VT 14 (1915–2023) AK 12 (1975–2018) RI 10 (1968–2018) SD 10 (1897–2015) VA 10 (1962–2026) ID 10 (1975–2024) KS 10 (1904–2023) NH 7 (1978–2021) OK 7 (1919–2011) DE 7 (1920–2015) WY 7 (1933–2009) NE 7 (1922–2013) NV 6 (1971–2018) KY 5 (1917–2009) ME 5 (1958–2020) SC 4 (1936–2009) PR 4 (1930–1967)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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